Knox v. Commissioner
United States Tax Court
Compensation received by petitioner in the taxable year 1943 for personal services allocable in part to the year 1942 under section 107, Internal Revenue Code, held to be subject to tax computation at the reduced amount provided by the Current Tax Payment Act of 1943, to the extent of the compensation allocable to the year 1942 under section 107.
1Opinion of the Court
OPINION.
Opper, Judge-.
Petitioner challenges respondent’s determination of a deficiency in income and victory taxes of $2,194.93 for the calendar year 1943.
The problem involves the interrelated effect of section 107 (a) of the Internal Revenue Code and the so-called “forgiveness” features (section 6) of the Current Tax Payment Act of 1943 upon income received in lump sums in 1943 for services rendered over a period of years including 1942 and 1943.
All of the facts have been stipulated and are hereby found accordingly. For purposes of this proceeding, they may be summarized as follows:
Petitioner…
Also in this document: Concurrence.
2Cases cited3 opinions
- Markham v. CabellSupreme Court of the United States · 1946
- Carpenter v. CommissionerUnited States Tax Court · 1948
- Stallforth v. CommissionerUnited States Tax Court · 1946
3Cited by18 opinions
- Hirsch v. CommissionerUnited States Tax Court · 1951
- Marshall v. CommissionerUnited States Tax Court · 1950
- Thayer v. CommissionerUnited States Tax Court · 1949
- Van Bergh v. CommissionerUnited States Tax Court · 1952
- Guest v. CommissionerUnited States Tax Court · 1948
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